Valuation Principles in the Income Tax Assessment Act

Abstract

The primary purpose of this article is to examine the concept of 'market value' and explain what factors make up the market place; it puts the concept of 'market value' in its proper context for the purposes of the application of the Act. Secondly, the article examines a particular aspect of the concept of market value; this concerns a proposition that in determining the market value of an asset there is to be excluded from the market all persons who can obtain and will pay for any special value from that asset because of its special adaptability or usefulness to those persons or because they can obtain synergistic advantages from it. Such persons are said to be prepared to pay a premium which is a 'special value' and are thus excluded from the market place because they are 'special purchasers' who are unrepresentative of others. Consequently, according to this proposition, that special value is excluded from the market value.